The Financial News Privacy and Cookies Policy

Effective February 21, 2012

1. INTRODUCTION

eFinancial News Ltd. ("Financial News", "us" or "we") is the data controller for the Financial News website, home page at efinancialnews.com, including when this website is accessed via the Internet, mobile or other device, and applications and sites affiliated with this website, including (but not limited to) the Financial News iPad application (collectively, the "Financial News Services"). eFinancial News Ltd. is owned by Dow Jones International, Ltd., ("Dow Jones"), and is part of the United States based operations of News Corporation.

This Privacy and Cookies Policy applies to all users of the Financial News Services and users of any related services, applications, or sites that link to this Privacy and Cookies Policy. By using our Financial News Services, you agree to the terms and conditions of this Privacy and Cookies Policy.

This Privacy and Cookies Policy does not govern the collection, use or disclosure of information in connection with any other Dow Jones products or services, or other methods for delivering any Dow Jones product or service, other than through the Financial News Services.

2. INFORMATION WE COLLECT

Personal Information You Submit. We collect all of the personal information that you submit to us, e.g., when you register for or subscribe to certain products or services, create a profile, participate in a sweepstakes or contest, take a survey, or use an interactive feature (such as Email-to-a-Friend). This may include your name and contact details, or any other information you submit, including your, occupation, interests, and feedback comments.

Information We Receive from Third Parties. We may receive certain information from selected third parties. Market research institutes such as Nielsen may provide aggregated demographic data or statistics on preferences and interests. Analytics service providers such as Chartbeat may provide aggregated information about user activities on our Financial News Services. Advertising service providers such as Audience Science may provide general information about user activities on other websites.

Information We Collect When You are Online. When you access our Financial News Services, we automatically collect certain information. For this process, we may use cookies and other tracking technologies (see the Use of Cookies and Other Tracking Devices for more details). Information collected when you are using the Financial News Services may include information about your computer and browser, potentially including your IP address, operating system, browser type, URL of the linking page if you arrive at Financial News Services via a link from another website, and other software and hardware information. We may also collect information on your region, continent, country, city, zip code, postcode, time zone, and other data to display relevant and personalised content.

We may further use these technologies to collect and store information about online activity, preference, and your usage of our Financial News Services, such as the pages you have visited, search queries you have run, and advertisements you have seen.

Information Collected by Third Parties. Information on site usage and other similar information, Internet activity, demographic information, and aggregated information may be collected by third parties that support our Financial News Services by serving advertisements or providing services, such as allowing users to share content, or tracking aggregate site usage statistics. Financial News may not control these third party technologies and their use is governed by the privacy policies of third parties using such technologies. For more information about third party advertising on our Financial News Services, see the section on delivering advertising below.

3. HOW WE USE YOUR INFORMATION

We use the information we collect from and about you for the purposes set forth below.

To Provide and Manage our Services. We use the information we collect from and about you to provide our products, services, and features to you. We use your information to process and fulfill your subscription, to send you information about your relationship or transactions with us, to allow for transition between the different websites, including access via the Internet, mobile or other device, and applications and sites affiliated with those products, to measure and improve those services and features, to conduct market research, to allow you to provide feedback on content, participate in online contests, promotions or rewards programs, to provide you with customer support, and to respond to your inquiries.

To Deliver Relevant Content and Recommendations. To make your experience more interesting and personalised, we may use any information we collect to assist us in delivering content on our Financial News Services.

To Deliver Relevant Online Advertising. We may use any of the information we collect from and about you to assist us in delivering relevant ads to you when you visit our Financial News Services. In particular, information on Internet activity, demographic information, and aggregated information may be used to limit the online ads you encounter to those we believe are consistent with your interests. For more information on how we use third party providers, cookies and other tracking technologies to assist with our online advertising please see below

We may work with third party online advertising companies and advertisers who help deliver online ads to you. We will not sell, rent, or share personal information with these third parties for such parties’ own marketing purposes, unless you choose in advance to have your personal information shared for this purpose.

To Contact You and Send you Promotional Materials. We may use your email address to respond to inquiries or requests you make to us, including sending you email news alerts. Subject to your approval, Financial News may also periodically send promotional materials or notifications related to our products and services to the email address you provided to us at registration or to your account. To help make these promotional materials more relevant to you, we may use information we collect to assist us in sending you promotional materials. If you would like to stop receiving promotional materials from us, you can change your settings by logging in and visiting the "My Profile" section of our website or following the unsubscribe instructions at the bottom of any of our promotional emails.

Note that there are certain service notification emails that you may not opt out of as long as you are registered with or subscribed to our products and services, such as renewal notices and notifications of changes to our products, services, or policies.

4. USE OF COOKIES AND OTHER TRACKING DEVICES

We use cookies and other tracking technologies (including pixels, beacons, and Adobe Flash technology) to improve and personalise the Financial News Services and for the other purposes explained in this Privacy and Cookies Policy. A cookie is comprised of small bits of data that often include an anonymous unique identifier. Websites send this data to your browser when you first request a web page and then store the data on your computer so the website can access information when you make subsequent requests for pages from that site.

We may use cookies to

facilitate our login processes;

identify returning users, registrants, and subscribers and to allow them to be presented with a personalised version of the Financial News Services;

enable you to move more easily around our sites, and to display relevant content, products, services and advertising, as described further below;

track your use of our sites to better develop our sites in accordance with your requirements;

collect and store information about your usage of our Financial News Services and your browsing pattern across sites, such as pages you have visited, search queries you have run, and advertisements you have seen, in order to make advertisements available to you that are more relevant to your interests.

We may also use cookies and similar tools to relate your use of our Financial News Services to personal information obtained from you or a reputable third party. For example, if you have asked us to provide you with information about our upcoming products or promotions, cookie and/or clickstream data about your activities on our Financial News Services may allow us to limit the materials we provide to you to items we think you will find interesting based on your prior online activities and preferences. You can delete cookies from your hard drive at any time, however this will mean that any settings such as your stored username and password will have to be reset. You can set your internet browser so that it will not allow cookies to be stored on your computer. This may reduce functionality of the site, prevent access to registration/subscription-only areas of the site and mean that certain features or content will not be available to you. Further information on how to prevent cookies from being stored on your computer can be found on http://www.allaboutcookies.org under the "manage cookies" section. Alternatively go to the help menu within your internet browser.

From time to time we may permit third party companies to set cookies on our sites for purposes which may include market research, serving advertisements, revenue tracking, to improve functionality of the site or monitoring compliance with our subscription agreement.

Financial News Services employs analytics services supported by third party companies such as Google, Adobe Omniture, and AudienceScience Inc. These third parties generate cookies for statistical purposes on our behalf, for example, for tracking how many unique users have seen a particular feature or advertisement, and how many times they have seen it. We do not have access to these cookies, although we may use statistical information arising from the cookies provided by these third parties for the purpose of evaluating your use of the Financial News Services, compiling reports on website activity and providing other services relating to website activity and browsing patterns across the Financial News Services and third party websites. These third parties have their own privacy policies and the information generated by the cookie about your use of our sites may be transmitted to and stored on servers in Ireland and the United States. They may also transfer this information to third parties where required to do so by law, or where such third parties process the information on their behalf.

Some of the advertisements you see on Financial News Services are generated by third party service providers and advertisers. Some of these third parties generate cookies for statistical purposes on our behalf, for example, for tracking how many unique users have seen a particular advertisement, and how many times they have seen it, and for providing advertisements that are more relevant to users. They do not contain identifying information such as your name or email address. This profile enables us to deliver more relevant advertising on our Financial News Services. For example if on a previous visit you went to our personal finance pages, we might find this out from your cookie, and we may then target personal finance advertisements on your subsequent visits to our websites which we think may be of interest to you.

To find out more about third party online advertising and to opt out of this type of advertising, visit www.youronlinechoices.co.uk or www.aboutads.info. Please remember that if you opt out of this type of advertising, you will still receive advertising when you are using the website, however, that advertising will not be tailored for you.

Financial News Services may use pixels, or transparent GIF files, to help manage online advertising. These GIF files may be provided by one of our Ad Management Partners, namely DoubleClick, Pointroll, Atlas, or MediaMind/Eyeblaster. These files enable our Ad Management Partners to recognise a unique cookie on your browser which in turn enables us to determine general geographic location, track how many unique users have seen a particular advertisement, and to re-target ads. For more information about Google DoubleClick, including information about their Dart for Advertisers (DFA) technology and how to opt-out, go to http://www.google.com/doubleclick. For information about Pointroll, and if you wish to refuse the use of cookies, go to http://www.pointroll.com/privacy.php. Information on Atlas Solutions is available at http://atlassolutions.com; opt-out is offered via https://choice.live.com/AdvertisementChoice/Default.aspx. More information about Mediamind/Eyeblaster, including how to opt-out of cookies, is accessible via http://www.mediamind.com/Content.aspx?page=privacy_policy.

5. HOW WE SHARE YOUR INFORMATION

Our Disclosure of Information

We only share your personal information with nonaffiliated third parties when sharing is permitted by you or authorised by this Privacy and Cookies Policy. In addition, we may share your personal information with our Affiliated Companies. eFinancialNews Ltd is the party responsible for the management of your information.

We also share your personal information:

To Manage Corporate and Third-Party Subscriptions. If your subscription is provided in whole or in part by your employer or another third party, we may notify the provider when you access or use your subscription. When providing these notices, we may reveal limited amounts of your personal information such as your name or email address.

To Allow Third-Party Service Providers to Assist us in Providing and Managing Our Services. We may make your personal information available to certain third-party service providers, such as contractors, agents, or sponsors, who help us manage or provide our products and services by, for example, developing or supporting products and features; storing customer subscription information; sending email messages on our behalf; processing payments; fulfilling orders; delivering subscriptions; auditing; processing data or statistics; or serving, customising or delivering marketing or ads. These outside service providers are required to protect personal information entrusted to them and not use it for any other purpose than the specific service they are providing to us.

To Permit Third Parties to Send You Promotional Materials. If you subscribe to Financial News Services, we will not sell, rent, or share your personal information with or to third parties for such parties’ own marketing purposes, unless you choose in advance to have your personal information shared for this purpose. We may, however, use the services of email delivery service providers, namely StrongMail. See http://www.strongmail.com/site/privacy-policy for more details on StrongMail’s privacy practices.

To Protect the Rights of Financial News and Our Users. There may be instances when Financial News may disclose information, including situations where we have a good faith belief that such disclosure is necessary in order to (i) protect or defend the legal rights or property of Financial News, our Affiliated Companies or their employees, agents, and contractors (including enforcement of our agreements); (ii) protect the safety and security of users of our products and services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process, including laws outside your country of residence; or (v) respond to requests from public and government authorities including authorities outside your country of residence.

To Complete a Merger or Sale of Assets. If Financial News sells all or part of its business, makes a sale or transfer of its assets, or is otherwise involved in a merger or transfer of all or a material part of its business, Financial News may transfer your information to the party or parties involved in the transaction as part of that transaction.

6. NOTICE

Means of Notice and Choice. This Privacy and Cookies Policy summarises our collection and use of your information. If we ask for specific personal information that will be used in a manner different from what is described in this Privacy and Cookies Policy, we will inform you at the time of collection.

Cross-Border Transfer. The information collected through the Financial News Services may be stored and processed in the United States and other countries where we have facilities or in which we engage service providers, and you consent to the transfer of information to the United States and other countries which may have different data protection rules than the country of your residence.

Data Retention. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy and Cookies Policy unless a longer retention period is required or allowed by law.

Linked Websites. Our Financial News Services may also be linked to sites operated by Financial News affiliates (i.e., that are part of Dow Jones & Company, Inc. and the News America Group, collectively, "Affiliated Companies") or third parties, and may carry advertisements or offer content, functionality, games, or applications developed and maintained by third parties.

Some of these third party sites may be co-branded with a Financial News logo, even though they are not operated or maintained by us. Financial News is not responsible for the privacy practices of any such third parties, and once you leave our Financial News Services via a link, enable a third party service, or click on an advertisement, you should then check the applicable privacy policy of the third-party site. Additionally, although all Affiliated Companies adhere to the News Corporation corporate Privacy Principles, users who visit an Affiliated Company site should still refer to its separate privacy policy, which may differ in some respects from this Privacy and Cookies Policy.

8. HOW TO ACCESS, CORRECT, OR UPDATE YOUR INFORMATION

You can access or modify personal information, or modify your preferences by contacting Customer Service for Financial News at customerservices@efinancialnews.com. Subscribers can also update personal data online and marketing preferences by signing in to their account and visiting the "My Profile" section of efinancialnews.com.